EU Digital Product Passport 2027: What every manufacturer needs to know
The EU is mandating digital product passports for batteries, machinery, and eventually all physical products. Here is a plain-English guide to what the law requires, who it affects, and how to get compliant before the deadlines hit.
Machinery deadline: January 20, 2027
EU Machinery Regulation 2023/1230 applies to all machinery placed on the EU market after this date. There is no transition period — if your machine ships after Jan 20, 2027, it must comply from day one.
Compliance timeline
Q1 2026
EU Battery Regulation pilot (large batteries > 2kWh)
Jan 20, 2027
EU Machinery Regulation 2023/1230 — digital technical file mandatory
Feb 18, 2027
Battery Passport mandatory for EV & LMT batteries
2028
DPP expands to textiles, electronics, construction products
2030
DPP mandatory for all product categories under ESPR
What data do you need to provide?
Each regulation specifies what information must be in the digital passport. Here is what each one requires:
Battery Passport (EU 2023/1542)
Manufacturer identity and address
Battery model, category, chemistry
Carbon footprint per kWh (A1–A3 lifecycle)
Recycled content % (cobalt, lithium, nickel)
Expected lifetime in cycles and years
End-of-life recycling and disassembly info
Due diligence on raw material suppliers
Machinery Technical File (EU 2023/1230)
Machine identification and serial number
Declaration of Conformity + notified body
Essential Health & Safety Requirements checklist
Risk assessment reference
Harmonised standards applied (EN ISO 12100…)
Technical drawings and schematics URL
Instructions for use in all EU languages
Cybersecurity documentation (if networked)
Generic DPP (EU 2024/1781)
Manufacturer name and product model
Carbon footprint (kgCO₂e)
Repairability score and spare parts availability
Recycled content and recyclability rate
Substances of concern
CE marking and applicable regulations
Declaration of Conformity URL
How AAS makes compliance tractable
The regulations do not specify a single file format — but the IDTA has published standardized AAS submodel templates that map exactly to each regulation's required data fields. When you fill in a Battery Passport submodel in AAS Studio, you are producing a file that directly satisfies EU Regulation 2023/1542.
The AAS format is also machine-readable, meaning downstream systems — your customers' ERP, logistics platforms, recyclers — can ingest it automatically without manual data re-entry.
Who is affected?
Battery manufacturers
EU 2023/1542
Deadline: 2027
Machinery OEMs
EU 2023/1230
Deadline: Jan 2027
Automotive tier suppliers
CATENA-X CX-0006/0026
Deadline: Now
Electronics manufacturers
EU 2024/1781 ESPR
Deadline: 2028–2030
Importers to EU market
All of the above
Deadline: Same as OEMs
Authorised representatives
As economic operator
Deadline: Same as OEMs
Start building your DPP today
AAS Studio has pre-built templates for every EU regulation listed above. Start for free — no credit card required.